- Page 1: UNITED STATES DISTRICT COURT SOUTHE
- Page 5 and 6: POINT III .........................
- Page 7 and 8: Capri v. Murphy, 856 F.2d 473 (2d C
- Page 9 and 10: Admin. Proc. File No. 3-4390, 1975
- Page 11 and 12: 143 F. Supp. 2d 304 (S.D.N.Y. 2001)
- Page 13 and 14: Milman v. Box Hill Sys. Corp., 192
- Page 15 and 16: Taylor v. Vermont Dept. of Educ., 3
- Page 17 and 18: Alan G. Hevesi, Comptroller of the
- Page 19 and 20: arguments withstands scrutiny. They
- Page 21 and 22: Asset Management, Inc. (“HGK”)
- Page 23 and 24: WorldCom’s stock and bonds. Moreo
- Page 25 and 26: illion. 5. 6 The accounting fraud,
- Page 27 and 28: method of committing financial frau
- Page 29 and 30: ampant “internal chicanery and co
- Page 31 and 32: would have seen billions of dollars
- Page 33 and 34: esponsibilities to investors. By th
- Page 35 and 36: even went so far as to ridicule inv
- Page 37 and 38: million. 228. Salomon often alloca
- Page 39 and 40: could of WorldCom, he never informe
- Page 41 and 42: e-mail admitted that he maintained
- Page 43 and 44: (Count IV). The Complaint also alle
- Page 45 and 46: various of the Underwriter Defendan
- Page 47 and 48: ought on behalf of other class memb
- Page 49 and 50: Complaint filed by the NYSCRF -- as
- Page 51 and 52: The Underwriter Defendants assert t
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The plain language of Section 11 es
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Retirement Income Security Act (“
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inconsistent with the overall purpo
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Pollack v. Laidlaw Hold., Inc., No.
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POINT II THE COMPLAINT STATES CLAIM
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omitted); see also Cromer Finance,
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his hand-picked CFO, then ordered t
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In addition, Ebbers contends that t
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much in charge and knowledgeable ab
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Ebbers’ motive to artificially in
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they specifically made. For example
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public statements, (b) failed to re
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Exchange and the National Associati
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Similarly, the Complaint alleges sc
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Tex. 2002). Significantly, each of
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For all these reasons, the fraud cl
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Further, the Complaint provides gre
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the other hand, when tidal waves of
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See Complete Mgmt. Inc. Sec. Litig.
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exerted” by U.S. senior finance m
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discredited this hypothesis. The ra
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statements for the Offerings or in
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ecommended violated anti-fraud prov
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y failing to disclose to his custom
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at the time the reports were issued
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2. Grubman’s Buy Recommendations
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continue to pursue the acquisitions
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allegations that establish that the
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facts, if taken as true, are certai
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4. The Complaint Adequately Alleges
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the stock. To the extent that the d
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conflicts of interest between Salom
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allege loss causation. 2000 WL 6406
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In Jacobs v. Coopers & Lybrand, L.L
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issued in connection with the Offer
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settled principle of law that direc
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Named Plaintiffs’ Counsel: BERMAN